“Personal Data” means data which identifies a person or could identify a person, such as their name, contact details, purchase history or web browsing history. It applies to Personal Data that we process in connection with your relationship with us as a customer, supplier, partner, investor, visitor to our website or prospective employee.

Every individual has a right to understand how their Personal Data is being used and to exercise control over it using data protection rights which are set out in the General Data Protection Regulation (“GDPR”). This Privacy Statement seeks to ensure that you know:
• what Personal Data we collect from you
• what we are doing with your Personal Data
• that we will only use your Personal Data for the purposes set out in our Privacy Statement
• your rights and can exercise control over your Personal Data

We make the following commitments. We will:
• not send you marketing emails if you do not want to receive them
• always ensure that we only share your Personal Data with third parties where absolutely necessary and only after thorough third party due diligence
• ensure appropriate technical and organisational measure are in place to protect your Personal Data and keep it secure

You can access our full Privacy Statement here. In it we provide further information about what Personal Data we collect, what we use it for, why we collect your Personal Data and what our legal basis is, who we share it with and how long we retain it. We also provide detailed information about your rights in relation to your Personal Data. If you have further questions, please get in touch with us at privacy@inhancetechnology.com.

If you wish to make a complaint in relation to the use of your Personal Data, you may contact the Irish Data Protection Commission at info@dataprotection.ie. You will be notified of any material changes to our Privacy Statement.

2. THE PURPOSE OF THIS PRIVACY NOTICE

We work with Suppliers to deliver highly accurate mobile diagnostics software to end users through easy to use customer journeys. We generally act as processors of Personal Data for Suppliers. ThisPrivacy Statement covers how we process Personal Data where we are controllers for the purposes of the GDPR.

We generally process Personal Data on behalf of insurers, carriers, enterprises and retailers globally (the “Supplier”) who provide our software application to the end user consumer for use on their mobile device. In the context of the end user we act as processors and the Supplier is a controller for the purposes of the General Data Protection Regulation in Europe (the “GDPR”).

This Privacy Statement sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us in those scenarios where we are controllers of that Personal Data for the purposes of the GDPR. Please read this Privacy Statement carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it.

This Privacy Statement is a statement of our commitment to protect the rights and privacy of individuals in accordance with data protection legislation including where applicable the GDPR.

2. THE PURPOSE OF THIS PRIVACY NOTICE

This section provides further information on the data subjects who’s Personal Data we process

This Privacy Statement provides specific information relating to the following data subjects where we act as controllers of their Personal Data for the purposes of the GDPR:

business contacts details including those of our partners, investors, customers and suppliers and business prospects;

users/visitors of our Website; and

those applying for jobs at the company.

Personal Data of employees of the company is dealt with in a separate internal privacy notice

4. CATEGORIES OF PERSONAL DATA

We have described here the categories of Personal Data that we collect as follows:

Financial Data : We collect payment details to take payment from you for the services provided by us.

Communications Data : If you interact with us we will record details of those interactions. For example, we will process details of phone calls, email correspondence and hard copy correspondence.

Recruitment Data: If we interact with you for the purposes of any job with the company we will collect recruitment related data such as identity data, CV data and application data as part of the recruitment process. We may collect diversity data such as gender, religion, ethnic origin, sexual orientation but only with your consent.

Web Data: When you interact with us online we will automatically collect data about your use of our services, including data on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This information is collected at an aggregate level and your identity data is not stored as part of this technical data.

5. OUR PROCESSING ACTIVITIES

We will only ever process Personal Data in compliance with data protection legislation and in a manner that you might reasonably expect.

We have set out clearly here the purpose of any processing activities we undertake and what our legal basis is.

We use your Personal Data to provide you with certain services and to assist us in the operation of our business. Under data protection law, we must ensure that the purpose of processing is clear.

We have set out below the general purpose of processing and the associated categories of Personal Data

Categories of Personal Data

Processing activity

Contact & Identity Communications Data

to send newsletters and other information that may be of interest to you;

to contact you re payments to and from you;

to contact you in connection with any job position we may have advertised;

to notify you of updates to this Privacy Statement;

for customer relationship management and support;

to send notifications about changes/updates to our products and services;

to fulfil our commercial and legal requirements

to contact you as part of our business relationship or for lead generation and general administration

to manage/respond to a complaint/appeal

Financial Data

to process payments to and from the business

Recruitment Data

to contact you in connection with any job position we may have open;

to fulfil the recruitment needs of the business;

to arrange interviews and follow up communications with you; and

to check your suitability for any positions we may have.

Web Data

to provide our products and services; and

to administer the Website and for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes;and

to ensure the safety and security of our website and our products and services.

6. LEGAL BASIS FOR PROCESSING

Here we provide further information about the legal basis that we use for processing Personal Data

All processing of Personal Data under the GDPR must be lawful. Processing will only be lawful if we have a legal basis for processing.

Our legal basis is either that a) you have consented to the processing; b) the processing is necessary for the performance of our contracts with you or in order to take steps at your request before entering a contract; c) the processing is necessary in order for us to pursue our legitimate interests; and/or d) the processing is required by law.

At times we will need to process your Personal Data to pursue our legitimate business interests, for example for administrative purposes, to provide information to you, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights. We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests and rights outweigh our legitimate interests.

If do not want us to process your Personal Data on the basis of our legitimate interests, contact us at privacy@inhancetechnology.com and we will review our processing activities.

We may need to use your Personal Data to comply with legal and regulatory obligations, including complying with your information rights, with reporting obligations and with court orders. We may also need to process your Personal Data to protect your vital interests or those of another person.

7. SOURCES OF PERSONAL DATA

Generally we collect Personal Data that has been provided directly by you and from sources where you would reasonably expect us to collect it from.

We will collect Personal Data from you when you interact with us, for example if we meet with you, or are introduced to you or you request information or support, use our services (including our websites) or purchase our products.

We may collect Personal Data about you indirectly, for example from your company or from your professional social media accounts in order to contact you about our business.

8. DISCLOSURE OF PERSONAL DATA

We share your Personal Data with a number of organisations for the purpose of providing our products and services to you. We may also share your Personal Data where this is necessary because of legal or regulatory requirements.

In certain circumstances, we may disclose Personal Data to third parties as follows:

business partners and sub-contractors including, payment processors, data aggregators and hosting service providers;

analytics and search engine providers that assist us in the improvement and optimisation of the Website. This consists of aggregated anonymous information only and relates to the web pages visited on the Website and not the information included on those web pages;

if we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us will be one of the transferred assets;

if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply the terms of any agreement;

to protect our rights, property, or safety, or that of you or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection;

as required by law, in order to respond to a court order or request from law enforcement or other public authority and in order to meet national security or law enforcement requirements. We will disclose your Personal Data if this is necessary to:

comply with a legal obligation;

protect or defend our rights, interests or property or that of a third party;

prevent or investigate possible wrongdoing in connection with our services;

act in urgent circumstances to protect the personal safety of one or more individuals; and

to protect against legal liability.

When we engage another organisation to perform services for us, we may provide them with information including Personal Data, in connection with their performance of those functions. We do not allow third parties to use Personal Data except for the purpose of providing these services.

9. SECURITY MEASURES

We are committed to protecting the security of your Personal Data and have implemented appropriate physical, technical and administrative safeguards.

We will take all steps reasonably necessary to ensure that Personal Data is treated securely in accordance with this Privacy Statement and the relevant law including the GDPR.

In particular, we have put in place appropriate physical, technical, and organisational procedures to safeguard and secure the Personal Data we process.

We use secure connections to protect Personal Data during its transmission using SSL (Secure Socket Layer) technology.

10. TRANSFERS OUTSIDE THE EEA

We will only transfer Personal Data outside the EEA if necessary and with appropriate safeguards in place.

Personal Data collected or received in the European Economic Area will only be transferred outside the area using legally approved transfer mechanisms such as the Standard Contractual Clauses or the Privacy Shield in the case of transfers to the USA.

11. COOKIES

Cookies help us improve the products and services that we offer you. Cookies are optional and you do not have to accept them. Further information on cookies can be found here.

You can adjust your browser settings to decline cookies or alert you when a website is attempting to place a cookie on your computer. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use (“third party cookies”), or those from specific websites. If you disable cookies you may not be able to access some of the features of our website.

Further information on the cookies we use are set out below:

Cookie

Cookie Name

Description

Universal Analytics (Google)

_ga

_gid

_gat

These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

12. THIRD PARTY WEBSITES

Our Website may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings and these are not endorsed by us. We do not accept any responsibility or liability for these third party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.

13. RIGHTS UNDER THE GDPR

You have a number of rights under the GDPR to control the Personal Data we use and how we use it. This includes the right to access your Personal Data, rectify inaccuracies, request that your Personal Data be deleted, restrict and/or object to the processing of your Personal Data and transfer your Personal Data to other entities. You may exercise these rights by contacting us via email at privacy@inhancetechnology.com , or by sending a letter to the following address: The Compliance Officer, Inhance Technology, 5 Cleve Business Park, Monahan Road, Cork, Ireland.

1. You can ask for access to the information we hold on you

You have the right to ask for all the information we have about you. When we receive a request from you in writing, we must give you access to everything we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.

We will provide the first copy of your Personal Data free of charge but we may charge you a reasonable fee for any additional copies.

We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.

2. You can ask to change information you think is inaccurate

You should let us know if you disagree with something included in your Personal Data.

We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

3. You can ask to delete information (right to be forgotten)

In some circumstances you can ask for your Personal Data to be deleted, for example, where:

your Personal Data is no longer needed for the reason that it was collected in the first place

you have removed your consent for us to use your information (where there is no other lawful basis for us to use it)

there is no lawful basis for the use of your information

deleting the information is a legal requirement

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.

Please note that we can’t delete your information where:

we are required to have it by law

it is used for freedom of expression

it is used for public health purposes

it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing

it is necessary for legal claims.

4. You can ask us to limit what we use your Personal Data for

You have the right to ask us to restrict what we use your Personal Data for where:

you have identified inaccurate information, and have told us of it

where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether

When Personal Data is restricted it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.

5. You can ask to have your Personal Data moved to another provider (dataportability)

You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

This right only applies if we’re using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.

6. You can make a complaint

You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.

14. RETENTION

We only keep your Personal Data as long as it is necessary for the purposes of processing it or to comply with legal or regulatory requirements.

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.

Our retention policy is as follows:

Processing activity

Retention Period

Sending newsletters and other information that may be of interest to you

Until you unsubscribe or there is no engagement with you or by you for more than two (2) years.

Use of Web Data

12 months

Candidates for job opportunities with the Company

18 months

Business contact information for the purposes of account management

For the duration of the contract and as required for audit purposes thereafter

Business contact information for the purposes of lead generation

Until you unsubscribe or if you don’t and no business relationship arises then two (2) years from the date of collection

General business contact information

During the relevant engagement and for a period of two (2) years thereafter

In certain cases we may retain Personal Data for longer than specified here if required under relevant laws.

15. AMENDMENTS TO THIS PRIVACY NOTICE

We may change this privacy statement from time to time.

We will post any changes on the Website and when doing so will change the effective date at the top of this Privacy Statement. Please make sure to check the date when you use our services to see if there have been any changes since you last used those services. If you are not happy with any changes that we have made you should cease using our services.

In some cases we may provide you with additional notice of changes to this Privacy Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

16. OUR CONTACT INFORMATION

Please contact us if you have any questions about this Privacy Statement or Personal Data we hold about you: